From: Annie Goodman [mailto:goodmanannie@comcast.net] 

Sent: Sunday, September 13, 2015 8:30 PM

To: EBSA, E-ORI - EBSA

Subject: 150913 - RIN 1210-AB32

Importance: High

Attention Labor Secretary Thomas Perez,

I am writing to voice my opposition to your proposed rule change to retirement accounts 

if it restricts my ability to trade options, futures or any other derivative products in 

traditional, rollover or Roth retirement accounts. There are millions of people like me 

who use these products to reduce cost basis of our long term investments. Writing 

covered calls, purchasing cash secured puts or any other combination of option 

spreads, etc. that do not involve naked calls is a powerful tool to grow retirement 

funds. Many retirees use these investment strategies to make ends meet. Do not take 

these products away from us.

I understand the need to protect people from “bad” investment advisors that charge 

outrageous fees or sell “bad” products. But throwing the baby out with the bath water is 

not the way to do this.

Please add language into your proposal that will permit and continue 

to allow options, futures and other derivative investment strategies in 

retirement accounts. Do not limit our choices to grow our retirement 

funds.

Below is additional concerns about your proposed ruling:

The following is information concerning a ruling by the Department of Labor that would hurt anyone 

trading options in a retirement account. That includes very basic strategies such as covered calls or 

selling cash secured puts. It will limit your ability to make money in your retirement account.

The U.S. Department of Labor ("DOL") has proposed a rule that it believes will reduce conflicts of 

interest between financial professionals/firms and retail investors seeking advice in their Individual 

Retirement Accounts ("IRAs"). The rule would establish a strict "best interest" standard for advice 

relating to IRAs that, among other things, would prohibit the use of options in broker-advised 

retirement accounts.

The DOL rule includes numerous detailed, complex conditions that would negatively impact retail 

investors like you, including limiting your investment choices.

As a result of this rule, many tools, research, and information services that were previously viewed 

as guidance or education will likely be deemed "advice" and subject to the fiduciary "best interest" 

standard. This means, without changes to the rule as it currently stands, your account, if considered 

a broker-advised IRA, would no longer be eligible for options trading. In order for you to continue to 

trade options in your IRA, we would likely need to remove most research, tools, and educational 

resources so your account would not be considered a broker-advised IRA. Or, we could convert your 

account to a fee-based investment advisory account in which options could be used. The first 
approach may limit your ability to make informed trading decisions and the second would likely 

increase your costs.

These IRA options issues arise because, for the first time in history, the DOL is proposing a limited 

list of "permitted assets" in broker-advised IRAs. Options are not on this list. So even if a brokerage 

firm were willing to restructure its business to fit within the strict conditions of this rule, it could not 

allow the use of options in broker-advised accounts.

As I stated above this ruling will hurt millions of retires that make ends meet by trading 

options in their retirement accounts. We all need more choices for growing our 

retirement accounts not less choice.

Annie Goodman

Edwards, CO 81632

Cell: 970-376-7105

goodmanannie@comcast.net